In this medical malpractice case, plaintiff S.V. alleges that defendants prematurely discharged her sister ("J.V.") from their care after J.V. was treated for seventeen days on a voluntary admission basis for psychiatric care at defendants' facility. The day after her psychiatric discharge, J.V. crashed her car into a utility pole, injuring plaintiff who was a passenger in the vehicle.
Plaintiff's medical expert contends defendants breached their professional standards of care by releasing J.V. prematurely while her medications were still being adjusted and her condition allegedly was not yet sufficiently stabilized. This "premature release" theory is at the core of plaintiff's claim of negligence. Notably, plaintiff did not argue below that defendants owed her a duty to warn her that J.V. was too unstable to drive a car, or of any other dangers relating to J.V.'s post-discharge condition.
The Law Division judge denied defendants' motions for summary judgment. Among other things, the judge rejected defendants' argument that they owed no legal duty to plaintiff in the circumstances presented. This court granted leave to appeal, limited to the discrete issue of whether defendants owed a duty to plaintiff with respect to her claims.
The court reverses the summary judgment ruling, applying the four-factor criteria for a legal duty under Hopkins v. Fox & Lazo Realtors, 132 N.J. 426, 439 (1993). Under the circumstances presented, defendants could not have reasonably foreseen that J.V., shortly after her discharge, would cause a motor vehicle crash that would injure plaintiff. In addition, plaintiff's theory of liability—alleging that J.V., a voluntary mental health patient, should not have been discharged—clashes with the terms of our civil commitment laws.